SPECTRUM BRANDS HOLDINGS, INC. PRIVACY POLICY

This Privacy Policy (the "Policy”) is effective as of November 7, 2017 (the "Effective Date”) and pertains to Spectrum Brands Holdings, Inc.'s, its affiliated companies’ and its subsidiaries’ (collectively, "Spectrum”).

This Policy describes Spectrum’s practices with respect to information it collects and receives from users of its website (the "Site"), including the types of information collected, how that information is used, and with whom that information is shared.

This Policy only applies to information Spectrum collects from the Site and does not apply to any other business activity of Spectrum. By accessing and using the Site, you agree and consent to the collection, maintenance and use of your information by Spectrum. If you do not agree to the terms of this Policy or do not consent to the collection, maintenance and use of your Personally Identifiable Information (as defined below) by Spectrum as described within this Policy, you should leave the Site immediately.

Spectrum/we reserve the right to revise this Policy at any time. When we do, we will give you notice of the revised Policy by posting it on the Site and by updating the Effective Date at the top of the Policy. You are responsible for regularly reviewing the current Policy.

PRIVACY OF CHILDREN

The Site is a general audience website. We do not intentionally collect Personally Identifiable Information (as defined below) from users of this Site who are under the age of thirteen (13). If we become aware that a user of our Site is under the age of thirteen (13) and has provided Personally Identifiable Information to us by using our Site (e.g., placing an order or entering a sweepstakes, contest or other promotion, etc.), we will remove that child’s Personally Identifiable Information from our files. Where necessary, we may use such information to provide notice to the parents of the users under the age of thirteen (13) who are using the Site.

WHAT INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We collect and store "Personally Identifiable Information" and "Automatic Information."

Personally Identifiable Information. "Personally Identifiable Information" is any information that tells us who you are, such as your first and last name, your postal address and zip code, your e-mail address, your telephone number, your hobbies and interests, and/or information regarding your pets and purchases.

We may collect Personally Identifiable Information from you if you register with our Site, sign up for our newsletter, purchase products on our Site, enter a sweepstakes, contest, or other promotion, submit a rebate or coupon request, or otherwise voluntarily provide such information to us (e.g., via our "Contact Us" webpage or in connection with ratings, reviews, requests for advice, suggestions, testimonials, or any user-generated content, such as photographs and/or videos).

You may choose not to provide your Personally Identifiable Information to us by leaving the Site immediately. Please note that if you do not provide such information, you will not be able to place an order with us or enter any of our sweepstakes, contests or promotions, and we may not be able to send you our newsletter, process your rebate or coupon request, and/or respond to your "Contact Us" inquiry.

We may use the Personally Identifiable Information we collect from you to send you our newsletter, process a purchase, rebate, coupon or other request that has been placed by you, notify you regarding sweepstakes, contests, and promotions and/or for marketing Spectrum’s products and services (or the products and services of affiliated companies or marketing partners) via email, postal mail, and otherwise.

Automatic Information. "Automatic Information" is information automatically collected by our webserver (which may be hosted by a third party) or third party services (such as Google Analytics) that your web browser automatically makes available whenever you visit our Site.

Automatic Information is not generally associated with Personally Identifiable Information, but if it is, the Automatic Information will be treated as if it is Personally Identifiable Information.

We receive and store certain types of Automatic Information whenever you interact with us. This includes "HTML Cookies." An "HTML Cookie" is a small amount of data that is sent to your browser from a webserver and stored on your computer’s hard drive. HTML Cookies provide a means for websites that you visit to keep track of your online patterns and preferences. Among other things, HTML Cookies help us identify returning users and customize our services to a user’s needs. By understanding which areas of the Site a user has visited, HTML Cookies allow us to present information, products, and specials that may be of the user’s interest.

Spectrum may also use "Flash Cookies," which tracks a person's Internet use across multiple websites and are not deleted or controlled by users in the same manner as standard HTML Cookies.

In addition to HTML and Flash Cookies, our webserver automatically recognizes and/or collects (when possible) certain information, such as your domain name, IP address, type of computer, type of web browser, screen size and characteristics (e.g., color, resolution), operating system, and/or the city, state and country in which you are located. An "IP Address" is a number assigned to your computer when you connect to the Internet. We may also collect information regarding your Internet browsing history (e.g., the site you visited before accessing our Site, the search engine and search terms that you used, and information about your previous visits to our Site), the length of your visit, the pages you viewed, your Internet service provider, the language settings on your computer, and/or certain software (e.g., Java support).

We may use such Automatic Information for purposes of system administration, to improve the design and content of the Site, and/or to enable us to personalize your Internet experience. We may also use such information in the aggregate to analyze Site usage and/or to assess the traffic to the Site.

This Site may have Google Analytics enabled. To find out how Google Analytics collects and processes data, read "How Google uses data when you use our partners' sites or apps" (located at www.google.com/policies/privacy/partners/).

HOW DO WE SHARE THE INFORMATION WE COLLECT?

We may transfer and otherwise disclose your Personally Identifiable Information and Automatic Information to third parties that are either subject to this Policy or follow practices at least as protective as those described in this Policy.

Without limiting the generality of the foregoing, we may transfer or otherwise disclose such information to third parties (a) for their marketing purposes, (b) that perform services on behalf of Spectrum, (c) in connection with the sale or purchase of subsidiaries or business units or the sale of Spectrum’s assets, (d) to meet any applicable law, regulation, legal process, or enforceable governmental request, (e) to protect and defend the rights or property of Spectrum or its affiliated companies, (f) to identify, contact, and/or bring legal action against someone who may have breached our Terms of Use, and/or (g) to act to protect the interests of our Site, users, or others as we deem necessary.

Do Not Track Disclosure. Spectrum does not track users’ behavior on our Site or across websites for the purpose of serving targeted ads, and, therefore, the Site does not respond to browser Do Not Track (DNT) signals. Third parties that have content embedded on Spectrum’s Site may set Cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific Spectrum Site from a certain IP address. Third parties cannot collect any other Personally Identifiable Information from Spectrum’s Site unless you provide it to them directly.

IS THE INFORMATION COLLECTED SECURE?

Information transmitted on the Internet and/or stored on systems attached to the Internet is not 100% secure. As a result, we do not ensure, warrant, or guarantee the security or integrity of such information. We will not be responsible for disclosure of any information due to errors in transmission or the unauthorized acts of third parties.

CAN I ACCESS THE INFORMATION COLLECTED?

If you would like to review the Personally Identifiable Information that we have collected about you online, please send your name, street address, telephone number, and e-mail address to us by regular mail to the following address:

If, after receiving such information, you would like to correct any factual errors, please note such correction and send them to us at the same address listed above so that we may make the corrections that you have requested.

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits users of our Site that are California residents to request a notice identifying the categories of Personally Identifiable Information that we share with third parties for their direct marketing purposes. If you would like to make such a request, please submit a written request, specifying that you would like a "California Privacy Notice,” to us by regular mail to the following address:

DO I HAVE ANY CHOICES REGARDING THE INFORMATION COLLECTED?

You may choose not to provide Personally Identifiable Information to us by leaving the Site immediately.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise this Policy at any time. When we do, we will give you notice of the revised Policy by posting it on the Site and by updating the Effective Date at the top of the Policy. You are responsible for regularly reviewing the current Policy. The most current version of the Policy may be reviewed by clicking on the "Privacy” or "Privacy Policy” hypertext located at the bottom of the Site. Your continued use of the Site after we post any revisions constitutes your agreement to any such revisions. If any such revisions are unacceptable to you, do not access the Site and do not submit any information to us.

Links to Other Websites. While you are using this Site, you may be linked or directed to other third party sites outside of our Site that are beyond our control. Each of these third party sites may have a privacy policy that differs from ours. For example, you might click on a link or banner advertisement that takes you off of our Site. These links and banners may take you to the sites of advertisers, sponsors, and co-branding partners. It is your responsibility to review the privacy policies of those sites. We are not responsible for any actions or policies of such third parties.

CONTACT INFORMATION

We welcome your comments regarding this Policy. If you have questions or concerns regarding this Policy, please contact us by regular mail at the following address: